White House Memo Justifying CFPB Takeover Was Written By Payday Lender Attorney

The lawyer who wrote the Office of Legal Counsel memo supporting the Trump administration’s viewpoint that the president can appoint Mick Mulvaney as acting director of the Consumer Financial Protection Bureau represented a payday lender in front of the CFPB last year.

Steven A. Engel wrote the memo for OLC, which has been criticized by academics for seeking a conclusion and working backward to justify it. “Let’s be honest, this is an argument where you get the answer, and then you go to the other side of the equation,” said former Rep. Barney Frank, D-Mass., a lead author of the Dodd-Frank Act, which created the CFPB. Engel was confirmed as an assistant attorney general earlier this month by a voice vote in the Senate.

But in July 2015, Engel was one of two lead counsels for NDG Financial Corp., a Canadian payday lender that CFPB cited for running a nine-year scheme to use its foreign status to offer U.S. customers high-cost loans that were at odds with state and federal law. “We are taking action against the NDG Enterprise for collecting money it had no right to take from consumers,” said CFPB Director Richard Cordray at the time. Engel was active in the case up until August of this year.

The revelation underscores the extent of industry infiltration of the structure designed by Congress — a single permanent director who can only take office upon appointment by the president and confirmation by the Senate — to keep the consumer watchdog independent of the industry it is set up to regulate and buttresses the original intent of the lawmakers who established the agency.

CFPB alleged that NDG, which issues and collects payday loans online, made “false threats” to consumers that non-payment would result in wage garnishment, arrest, or imprisonment. The web of companies in the enterprise, situated in Canada and Malta, did not have the legal right to debit accounts to collect payday loans in the U.S., but they hid behind their foreign status to claim that they were exempt from various limitations and statutes. The case is still active in federal court in New York.

Engel represented the defendants in the case against CFPB as recently as this August, when U.S. District Judge Colleen McMahon asked judges in Canada to compel testimony from Canadian banks. At the time, Engel was a partner at the law firm Dechert. He was nominated to become an assistant attorney general for OLC in February of this year.

Having a former adversary to CFPB weigh in on who is the legal acting director of the agency raises questions over Engel’s independence and potential conflict of interest.

In the OLC memo, Engel argued that the Federal Vacancies Reform Act allows President Donald Trump to name Mulvaney as acting director of CFPB, instead of the current deputy director, Leandra English. In response, English has sued the president and Mulvaney, seeking an injunction to prevent the appointment.

The situation has caused chaos within the agency, which has the mission of safeguarding consumers against unscrupulous financial products. The CFPB’s general counsel, Mary McLeod, issued a three-page memo over the weekend agreeing with OLC’s take and saying that personnel should “act consistently with the understanding that Director Mulvaney is the Acting Director of the CFPB.” McLeod leaned heavily on the OLC memo in her analysis, which was bitterly contested by severallegal scholars.

Some have suggested that internal politicsplayed a role in the CFPB general counsel memo, with a split between those who want to play nice with the new regime and those who want to retain the agency’s independence. There is additional talk of unhappiness inside the building with the English selection over former acting deputy director, David Silberman.

Advocates of English as the proper director argue the House specifically made allowance for the Federal Vacancies Reform Act to govern succession in its version, while the Senate did not. In the conference committee, negotiators opted for the Senate version, which suggests Congress knew how to make the FVRA apply, but actively chose not to. McLeod called the argument “unpersuasive,” reasoning that the Senate language was chosen simply because its version of the directorship won out.

Frank told The Intercept that the Senate language was his preferred approach to begin with, but he never had the votes in the House due to turf issues with then-Energy and Commerce Chair Henry Waxman, D-Calif.:

The House version did not reflect what I wanted. Waxman was chair of the Energy and Commerce Committee, he was being turf conscious. He was concerned because the consumer bureau was being given more power than FTC, which was under his jurisdiction. He was worried that the CFPB would somehow overpower the FTC. I wanted to give them that power. Waxman wanted a five-member commission. I got a compromise of a single director to start, and then the commission. The Senate went with a single director. When we went to conference committee, I sort of gave in without a fight. So the Senate language is more relevant. I didn’t have the votes in the House for a single director. I did have them in the conference committee. The Senate language was a reflection of what Senator Dodd and I preferred.

The succession provision was part of Congress’s intent to keep the agency independent of the president, Frank said. “We gave the director unusual independence from the president, including a five-year term. This [provision] makes that effectual,” Frank said. “Our intention was to give a full five years of independence. This was part of it.”

The president still has the ability to appoint a successor, said Frank, but only one who would not destroy the agency, as such a nominee would not get through the Senate. “The way it works, the acting director stays in until a confirmed successor appointed. I don’t think the Senate would confirm someone like Mulvaney, who would destroy the agency. Remember, Senator Collins is in there and she voted for it. Republicans would like to get rid of the agency legislatively, but they don’t have the votes,” he said.

Former Rep. Brad Miller, D-N.C., the lead champion of the CFPB provision in the House, also said it was the intent of the bill’s authors to keep the acting director independent of the president. “We were very much about the task of trying to create an independent agency that would not be captured by its opponents,” he said. “The statute’s pretty clear. What happens if there’s a vacancy in the director’s spot, the deputy director steps up and serves until the Senate confirms a replacement.”

Democrats, in the past, have respected the process for other agencies that have similar succession plans, including the Federal Housing Finance Agency. “We did the same thing with the FHFA. There was a desire to get rid of [then-FHFA Acting Director Edward] DeMarco,” Miller recalled in an interview with The Intercept. “We couldn’t find a way around it because the statute was really clear. It said if there was a vacancy, the statute requires Senate confirmation. The president just can’t appoint someone to serve. It’s the same thing here, there’s a clear statutory succession.”

Laurence Tribe, a renowned constitutional scholar at Harvard Law School, agreed that the statute is clear.

The OLC, in the memo filed [over the weekend], to its credit, admits that the references to unavailability and absence encompass vacancy. They’re not trying to argue that the statute doesn’t cover this. They’re trying to have it both ways. They’re arguing that the president retains an option under the Federal Vacancies Reform Act to override subsequent legislation. They’re trying to have half a loaf and make it a whole loaf. It’s an interesting position but it collapses on itself. It’s completely incoherent. Laws are not typically written that way.

Senate Minority Leader Chuck Schumer, D-N.Y., pushed back against the Mulvaney pick. “The process for succession laid out in Dodd Frank is clear: Leandra English, not Mick Mulvaney, is the acting director of the CFPB. By attempting to install Mr. Mulvaney as director, the Trump administration is ignoring the established, proper, legal order of succession that we purposefully put in place, in order to put a fox in charge of a hen house,” he said in a statement.

The Justice Department did not respond to a request for comment about Engel and whether he should have recused himself from matters involving the CFPB.

For Miller, the fight over the CFPB bleeds into a broader effort by the business community to shore regulatory agencies of their independence. “It is a bigger fight. It’s sort of been gathering. The right wing has been trying to chip away at independence for a long time. This is one part of that battle. Do I think Trump is deeply studious about specific vacancy issues? No. People he staffed his administration with reflexively supports whatever the Business Roundtable wants. They want easily captured agencies,” he said. “The stuff CFPB does is wildly popular with the American people. The idea that Americans are chafing at their lack of freedom to get predatory financial products is laughable.”

Update: Nov. 27, 11:09 a.m. This story was updated to include interviews with Barney Frank, Brad Miller, and Lawrence Tribe, and a statement from Sen. Chuck Schumer.

Top photo: Former Consumer Financial Protection Bureau Director Richard Cordray testifies during a hearing before the TARP, Financial Services and Bailouts of Public and Private Programs Subcommittee of the House Oversight and Government Reform Committee on Jan. 24, 2012 on Capitol Hill in Washington, D.C. The hearing was to focus on the Consumer Financial Protection Bureau.

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This is the most absurd ruling . The Frank -Dodd law made a provision to protect the CFPB from any government interference. Unfortunately the writers of this law didn’t count on a Trump appointed judge ruling in error for the Trump appointee.

I’ve a feeling there might be an important story buried in this article somewhere but without half-decent sub-editors and editors it’s impossible to tell. Only an insider’s insider would have the patience and tenacity to try to get to what this story is about.

That strikes me as male-centric view. Having an organism developing inside someone which can change there emotional state, induce nausea, changes the physicality of your body and can lead to death or other health complications is absolutely a “health care” issue

It is much more Draconian than that. If it helps the average American, destroy it…while telling the suckers it’s good for them, it will save them money and that some group which is intent in destroying ‘Murika’ is behind it (usually big scary Liburals, the ones that can’t even wipe their asses properly).

Payday loans are a lifeline to many, many of the low income families that fall short paying the bills and putting food and shelter in place at the end of the month. What needs to change is the pay people get. DON’T TAKE AWAY A IFELINE. It’s like taking opiates away from those in pain!

The Consumer Financial Protection Bureau did NOT put any of these “payday loan” companies out of business, it only stopped their completely unconscionable practices.

Perhaps you have a valid point to make still, but suggesting the CFPB was putting these predatory vultures out of business isn’t one.

As someone familiar with the topic at hand, the CFPB’s goal absolutely was to put the industry out of business. The problem with doing so is that there are literally no other way to get short term small $ loans from a legal business. There is a demand for that kind of product. Like it or not, without the payday industry, the only option left is loansharks.

Perhaps the next time anyone thinks that anyone with a D on their jersey is as good as any other with a D on their jersey they’ll be reminded just how awful this last presidential cycle was, what with the two least liked presidential candidates in U.S. history on the ballot and remember that just because someone has a D on their jersey doesn’t mean they’re for We, The People.

Anyone who thinks the only problem is Trump and / or the Republicans is seriously delusional.

Agreed.
Many people confuse their political identities as being akin to the kind of loyalty they pledge to a favorite sports team – running the risk of developing a condition of partisan Stockholm Syndrome.

When my choice for Chief didn’t get our troops out of Afghanistan and Iraq, as promised during his campaign, that was it for me.

At the same time, I didn’t swing wildly in the opposite direction.
However, I did start drinking a bit more…

I’m sure that Trump’s ascendancy has not only helped the main stream media but also the alcohol industry. … I bet the drunk-driving statistics are going to show a blip on the long-term graph! Future historians will wonder what that was all about!

It pains me to argue contra on this — and I’m not purporting to *defend* Engel’s integrity/independence so much as to argue for the distinction between particular interests and the lawyers who defend those interests. In other contexts, this publication has strongly pushed back against this suggestion. For example when some Obama critics protested the hiring by DOJ of any lawyer who had defended an alleged terrorist, arguing “bias.” Basing conclusions on conflict of interest or bias on whom a lawyer has represented undermines the functionality of an adversarial legal system, which requires that all interests have access to vigorous counsel.

Yes, the revolving door is a problem. But discrediting a specific legal opinion by reference to the author’s former clients is unhelpful. It wrongfully equates a lawyer with his/her client and doesn’t offer relevant context or insight for judging the actual merits of the legal opinion.

Dayen is attacking the messenger, not his argument. A major flaw in his reasoning.

We simply shouldn’t allow administrations to start bureaucracies that live without political oversight from then on, because every administration will then start it’s own bureaucracies and they will grow without end, and start fighting against each other. Because the people running them will all owe their allegiance to the politician that created their jobs, and work for him from then on. You know they’ll appoint successors with the same political point of view and personal interests from then on.

We simply shouldn’t allow administrations to start bureaucracies that live without political oversight from then on…

…And we don’t.

The agency in question was created by congress. They realized the political climate and decided to HELP make the institution as removed from politics as was reasonable at the time, and they did so. It was precisely their point to avoid exactly the issues you cite. If you can propose a better way, then I suggest you do.

From the now-public McLeod memo, it looks as though Cordray was being advised by his own GC that his plan might not work. Of course he can disagree, but the point is he certainly knew there was legal uncertainty around his naming a successor and, in that case, the way he went about it was ham-handed and sloppy–an obvious unforced error. He should have hired a deputy long before resigning, rather than make it an event literally upon leaving office, passing over the acting deputy to appoint his chief of staff hours before leaving. He needlessly made the succession seem less like automatic administrative functioning, “independent” from politics, and more like a stunt to control which political influence prevails — the last administration or the new one. The law is the law, but it doesn’t help when the optics undermine your core argument around independence.

Payday loans are a lifeline to many, many of the low income families that fall short paying the bills and putting food and shelter in place at the end of the month. What needs to change is the pay people get. DON’T TAKE AWAY A IFELINE. It’s like taking opiates away from those in pain!

Have you seen the interest rates payday loan folks offer? It’s criminal and should be illegal to charge more than say 5%, at the most. How about using the federal interest rate? Exploiting and praying upon the poor is what the payday folks do. They are not doing anyone any favors.

Simple: Because they don’t have to and because they are “bound by law” to not do so.

I’m sure it’s beyond your notice that many if not most corporations charge the maximum that they think people will pay. And, if by chance some wayward CEO of a predatory lender like this WANTED to charge less, they’d likely be sued under the (relatively modern) legal concept of “fiduciary responsibility” which posits that any corporate executive that fails to extract the maximum dollars possible is therefore guilty of being feduciarialy irresponsible. Check this out, “it’s a thing.”

“Payday loans are a lifeline to many, many of the low income families that fall short paying the bills and putting food and shelter in place at the end of the month.”

It is tragic – and sadistic – that it has come to this. People arguing in favor of payday loans as being a lifeline to poor people. If payday loans are a lifeline, then, for that matter, so are credit cards, loan sharks, bank robbery, prostitution or selling your kids to the highest bidder. Instead of arguing (and defending) the benefits of usury and opportunistic payday loans, how about addressing the fact that working class wages have been stagnant for over 40 years? Unlike the Trumps, the little people can’t afford the luxury of filing bankruptcy when they have to rack up credit card debt or payday loan debt simply because their family needed food or healthcare. And this is the crux of the problem that is allowing vulture capitalism to step in and close the gap being left by some of the lowest wages in the so-called modern world and profit from neo-feudal practices such as this one which exploit the misery of the many. When you have a society where the combined fortunes of three individuals amounts to more than the combined meager earnings of one half of the population (that is 150 MILLION people), you have a problem. And guess what? Payday loans and similar legal loan sharks ain’t gonna fix that.

Your analogy, “It’s like taking opiates away from those in pain” is true but not in the way you intended, I expect. Inappropriate prescription of opiates has contributed mightily to the opiate addiction pandemic that is sweeping the nation, in much the same way as payday loans with their usurious interest rates produce a cycle of dependency among those who have no access to conventional lines of credit. I totally agree with Joe that there should be regulations that limit the maximum interest rate that can be charged.

The payday loan industry talks out of both sides of their mouths when they argue that they have to charge high interest rates because the borrowers are risky, but the borrowers are risky precisely because of the high interest rates they are forced to pay.

“Payday loans are a lifeline to many, many of the low income families that fall short paying the bills and putting food and shelter in place at the end of the month.”

It is tragic – and sadistic – that it has come to this. People arguing in favor of payday loans as being a lifeline to poor people. If payday loans are a lifeline, then, for that matter, so are credit cards, loan sharks, bank robbery, prostitution or selling your kids to the highest bidder. Instead of arguing (and defending) the benefits of usury and opportunistic payday loans, how about addressing the fact that working class wages have been stagnant for over 40 years? Unlike the Trumps, the little people can’t afford the luxury of filing bankruptcy when they have to rack up credit card debt or payday loan debt simply because their family needed food or healthcare. And this is the crux of the problem that is allowing vulture capitalism to step in and close the gap being left by some of the lowest wages in the so-called modern world and profit from neo-feudal practices such as this one which exploit the misery of the many. When you have a society where the combined fortunes of three individuals amounts to more than the combined meager earnings of one half of the population (that is 150 MILLION people), you have a problem. And guess what? Payday loans and similar legal loan sharks ain’t gonna fix that.

They do not plan to release anything publicly, so no posting online or anything public-facing, just to the committee. That said, they are considering placing a story with a friendly at the AP (Matt Lee or Bradley Klapper), that would lay this out before the majority on the committee has a chance to realize what they have and distort it.
On that last piece, we think it would make sense to work with State and the AP to deploy the below. http://podestaemails.blogspot.com/2017/11/clinton-campaign-staff-conspire-to.html

I would presume that the genuine administrator showed up and had a lot easier time getting in since he already works there. And, I’d presume he’d arrive with a copy of the various laws and started his day by explaining the law to any of the top lieutenants who didn’t already know he was the genuine authority. … And then set the record straight; unless / until a court orders otherwise, continue with your work following MY direction, not the Trump-dude…

Predatory financial products? Basically all student loan deals, from both government-backed and private lenders, fall into this category. Donald Trump declared bankruptcy what, four times? Student loan holders can’t even declare bankruptcy once. Clinton Democrats and Republicans are united in their desire to keep this system intact, to keep young college graduates trapped in a cycle of perpetual debt, for the rest of their lives. Basically, it’s a program to create indentured servants.

There’s only one way out of this: allow student loan holders to declare bankruptcy, just as Donald Trump and his pals are able to, to get out from under their crushing debt burdens. This is what Wall Street really doesn’t want – and Trump, like Obama, rolls over for Wall Street.

Well, you have to keep in mind that students can declare bankruptcy, but it ain’t easy. Here’s an informative link. All the cards are stacked against the students, but declaring bankruptcy is no party for anyone.

And one quote stood out to me from the Taibbi article you linked to:
“Nailor certainly was unaware of what he was getting into when he was 19. “I had no idea [about interest],” he says. “I just remember thinking, ‘I don’t have to worry about it right now. I want to go to school.’ ” He pauses in disgust. “It’s unsettling to remember how it was like, ‘Here, just sign this and you’re all set.’ I wish I could take the time machine back and slap myself in the face.”

Sounds like a man taking some personal responsibility.

Look, I agree this is a fiasco, it can’t be denied after reading Taibbi’s piece. I myself co-signed for a student loan for my brother’s girlfriend’s son (after being called an idiot for even thinking about it). So far, so good, but hardship may befall, and that does worry me quite a lot. At the very least it should be made easier to discharge student loans in times of hardship. That’s going to take legislative action; the CFPB enforces the laws, it doesn’t write them.

And sorry for implying you’re a cucumber in a previous post on this issue. I appreciate your passion, and largely support your view. I’m just not sure the CFPB is the right target when it comes to student loans. I would appreciate a lesson to the contrary.

Student loans wouldn’t be offered if they could be eliminated by bankruptcy. Once students got their sheepskin, they’d just declare bankruptcy since they typically have no assets freeing them of large loans. Before the government got involved, it usually required a co-signer with sufficient assets to collect to get a loan. But lenders wanted to loan money for college, and got the government to change the rules.

But you know who’s at fault? The students who took out such loans without first a) evaluating they’d make enough to pay it back to make it a good investment, b) they had the skills, discipline and resources to get the degree.

As you say, they are legally indentured servants, thanks mostly to their decisions.

And that would force colleges to either lower tuitions or close entirely – or there’d be mass reforms over higher education financing in the United States – or the United States would become technologically backwards relative to China, Germany, Japan, and continue sliding back into Third World status.

The current system, dictated for the benefit of Wall Street con artists and banksters, is not inevitable. It can be changed – just as FDR did in the 1930s. Wall Street doesn’t want this, but who cares what those criminals want? They’ve been the ticks on the American middle class for long enough.

here is another example of the the operation of the government that favors a tiny fraction of US citizens over the majority.
The idea we live in a democracy is laughable. The president gets 800,000 more votes in three states but gets 3 million less over all is not democracy it’s just gaming the system.
the majority Americans want some form of gun control. They want they ACA to work, they want legal marijuana, They want net neutrality, They want safe clean air, water and food. They support renewable energy sources, they believe in climate change, evolution, and want legal abortion, they want public education, fair drug prices and on and on.
But we get little or none of it. The government gets blamed and nobody trust the government because it is run to enrich a tiny fraction of the population. But it’s never been the government it’s the people in the government like all the idiotic and incompetent rich people of this administration.
The only comforting fact is it has always been this way and in the past it was way worse when the military would be called out to intimidate, injure
and kill those who stood up and fought back.

Put your idiotic butt hurt about the election behind you; they were BOTH bad choices! Time to move on and DO SOMETHING USEFUL!

Sure, we’re in a fascistic state now – have been for a long damned time, it’s just that now people are starting to awaken to reality. Sure, we get nearly nothing of what we want and need, and yes, we have to be mad as hell and not take it any more. (Just don’t be stupid and think that any Dem is good because they’re not an R because that’s the kind of thinking that got us here in the first place; POLICY matters, not just the letter on the back and color of one’s jersey.

The FACT is that Trump’s victory has awakened the masses in a way that we haven’t seen since the late 1960s or very early 1970s, and that’s a DAMNED good thing.

There’s a VERY reasonable argument – proven neither way so far – that we’re in better shape now with Trump having been elected precisely because it has awaken “the left” which has, on whole, been asleep since about 1975. WHERE WERE THEY in combating CLINTON (Bill, of course) when he gutted welfare, trashed media with the “telecommunications act”, upped the war on The People (especially “people of color”) otherwise known as The War On Drugs, and on and on and on?! Or, in the exact same ways, Obama? Oh, he’s black? Right? Anyone who supported these two presidents without these and even much more profound criticisms thrown in the mix are abjectly either NOT “left” or ARE blinded by “identity politics” which (for the most part) puts the color of and the letter on your jersey as more important than your policies.

For heaven’s sake STOP with the identity politics bullshit: Vote in EVERY primary for the very most progressive people you possibly can and for heaven’s sake STOP voting for ANYONE just because they have a D on their backs. Better vote “third party” than for some “D” who is just as bad as the R you think you’re avoiding.

Republican voters consistently support kicking the poor and middle class while they are most in need. Interestingly, some of these same voters are themselves poor or middle class. I don’t understand why some people vote “more for the rich, and less for me.”

Republican votersAll Republican and most Democrat politicians consistently support kicking the poor and middle class while they are most in need.

There FIFY. ;-)

And this surely bears repeating:

Stop voting for D’s just because they have a D on their jersey. POLICY matters; “blue dog Democrats” are just Republicans by another name. Vote in the primaries for the most progressive person you can possibly vote for! We need the Democratic Party bench to have not a single member who isn’t a progressive.

The foxes are not only guarding henhouses,(Americans) they are encouraged to now feast on the chickens and gluttony is richly rewarded. Congress has already given its blessing or will soon shortly. What little democracy was left is rapidly fading from memory. RIP

CFPB’s general counsel, Mary McLeod, is no John Yoo but seems well qualified in hair-splitting legalese.

Reading over her a three-page memo, she makes no bones about the statutory requirements ” 5 U.S.C. § 3347(a). Section 1011(b)(5) of the CFPA, 12 U.S.C. § 5491(b)(5), is on its face such a statute. It states that the Deputy Director “shall … serve as acting Director in the absence or unavailability of the Director.” The Vacancies Act thus does not extinguish the authority of the Deputy Director to serve as the Acting Director under 12 U.S.C. § 5491(b)(5).”

Now, here’s the brilliant legalese hair-splitting twist:

At the outset, there is a debatable question as to whether the phrase “absence or unavailability” is broad enough to provide authority for the Deputy Director to serve as Acting Director in the situation of a vacancy created by a resignation.

I mean, who else but a brilliant legal mind would even consider such a proposition? Surely, not many experts would equate ‘resignation’ with ‘absense or unavailability’?
That’s adjunct prof. quality at John Yoo’s school of legalese @ Berkeley Law … at least.

*I fully expect the courts, such as they are, to throw this back to congress … where it will die a slow and painful death.

when do these scumbags stop!! trump has no doubt make a mockery of this nation. his alleged “mandate” to maga is rife with FRAUD! he appears to be using the office which he stole (#notmypresident) from the American people to enrich himself and his family and friends. where is the hue and cry for a recall of the banana republic “fake presidential vote” of 2016. come on folks wake the f up! A PAYDAY LENDER LAEYER??? is looking out for you? that’s a better one than CLEAN COAL.

You’ve been doing some great reporting about this, but now I see two legal interpretations — one in a three page memo and one delivered in Twitter snippets from some guy, unless his feed has something a way back I didn’t look at. Guess what — you’re not winning! Point us at a decently written multi page argument. Is “the absence of the director” the same as “the absence of a director”? I have no clue. I could certainly believe the bastards from the payday lender have the better lawyers, both to read them and to draft them, and it’s possible a thing like the financial future of generations shouldn’t be settled by trying to read a sentence, but could better be settled by illiterate peasants with pitchforks.

It is the corporations that have finally taken over the government, including the White House.We sit with our eyes glued to the media watching the distractor-in-chief not seeing or caring what is going on behind the doors. When will we wake up?

If everyone in Washington who had ethical conflicts were to recuse themselves, there wouldn’t be any sharks left in the tank. Also, just off the top of my head, the CNN moderator who didn’t know enough to counter the BS sounds like Wolf Blitzer.